Strettons is committed to protecting and respecting your privacy, and we value any personal data we have in our organisation. This policy, together with any other documents referred to in it, sets out the basis on how any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and the care in which it will be handled.
The Strettons website (www.strettons.co.uk) is owned and operated by Strettons.
WHO WE ARE:
WHAT IS PERSONAL DATA?
Personal Data is defined as “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
THE DATA CONTROLLER
A data controller is the individual, legal person or entity that controls and is responsible to keep and use personal data in paper or electronic files. Strettons is the data controller as defined by relevant data protection laws and regulation.
THE DATA PROCESSOR
A data processor is the individual, legal person or entity which processes personal data on behalf of the controller.
The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever personal data is to be processed:
(a) Consent: you have given Strettons clear consent for your personal data to be processed for a specific purpose.
(b) Contract: the processing is necessary for a contract Strettons' have with the individual, or because Strettons' have asked the individual to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for Strettons to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for Strettons to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for Strettons’ legitimate interests, or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.
DATA SUBJECT RIGHTS:
(1) The right of access.
(2) The right to rectification.
(3) The right to erasure or right to be forgotten.
(4) The right to restriction of processing.
(5) The right to be informed.
(6) The right to data portability.
(7) The right to object.
(8) The right not to be subject to a decision based solely on automated processing.
(9) The right to withdraw consent.
You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com
WHAT KIND OF PERSONAL DATA DO WE COLLECT?
In order to provide lettings and sales services to our clients, we are required to process certain information about tenants and purchasers. We will only ask for details that are necessary to help you find or complete a transaction on a property. This includes details such as your name, email address, telephone number(s), credit records, workplace, professional specialism(s), bank statement, solicitor’s details, and other required information.
Where appropriate and in accordance with regulatory or legal requirements, we may also collect information related to your immigration status, sources of funds or details of any misconduct our clients may need to know about. We also collect your bank details to process payment of fees for other services which you contract from Strettons. We may use your email address and property requirement to send you relevant properties throughout your search, but you are free to opt-out and close your property search at any time or ask to be removed from our database.
If you are a buyer or a landlord, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as:
(1) auctioning your property
(2) providing you with support in letting or selling your property (or assisting another organisation to do so)
(3) providing you with insurance services (or assisting another organisation to do so)
We will only collect what is necessary to carry out a service and for regulatory or legal requirements. We also ask for your bank details to process any fees payable or for payments for other services that you have instructed Strettons to provide.
We need a limited amount of information from our Suppliers to ensure that we can facilitate services or property transactions. To do this, we will ask for company email addresses and phone numbers of relevant individuals at your organisation so that we can communicate with you/them. We also need other information such as your bank details so that we can pay for the services you provide if this is part of the contractual arrangements between us.
HOW DO WE COLLECT YOUR PERSONAL DATA?
DIRECTLY FROM YOU:
Personal data might be given to us in several ways including via:
- Entering your details on the website to subscribe to our mailing list
- Entering your details on the website to submit an enquiry about a property or service
- An application form, as part of the landlord/seller/buyer/tenant registration process
- A form to apply for a job at Strettons
- A form or other request for information about Strettons or a property(ies)
- Emailing your CV to Strettons for a job vacancy
- A form to participate in an auction
- An auction catalogue order
- A form to act as a guarantor
- A form to register for events and any hard copy registration at events
- Contacting us with enquiries or comments by telephone, email or hard copy correspondence
- Collecting your data through a contractual or commercial relationship with you
- Very rarely, but occasionally, we may obtain an email or mailing list through a reputable source in order to reach a new audience we think might be interested in our services.
FROM A THIRD PARTY:
Personal data may be given to us by another organisation you have registered with and we may be required to process your data in order to complete services that you or the organisation expects of us. This could include one of the following:
- Property portals (Rightmove, Zoopla, etc.)
- Credit Reference Agencies
- Other regulatory bodies to check your financial conduct or history to comply with Anti-Money Laundering legislation or other legal regulatory instruments we are bound by.
We collect your data automatically through cookies when you visit our website, in line with cookie settings in your browser. We may collect information about your computer, operating system and browser type for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual unless you choose to complete a form. More information on cookies and the data they capture on our site are below.
HOW DO WE USE YOUR PERSONAL DATA?
The personal information we record is used to communicate with you when you request information about a service or a property we are marketing. Data is processed by Strettons, and depending on which service Strettons is, providing we will have a set list of authorised suppliers that you will be made aware of before sharing your information.
No other third parties have access to your personal data unless it is specifically required to meet either contractual obligations or the legitimate interests of the company as defined under Article 5 of the GDPR. If at any time you do not wish to receive further information about us and our services, all communications will provide an easy opt-out and opportunity to update preferences. If you want to be removed from all databases, please contact us: firstname.lastname@example.org.
HOW DO WE PROTECT YOUR PERSONAL DATA?
The data that we collect from you will be processed at our servers in the UK. It may also be processed by organisations operating in the EEA that Strettons has instructed.
If Personal Data is transferred outside the UK or EEA to a country without a designated adequacy rating Strettons will request the data subject's consent before processing the data. Consent will not be sought where the Processor's Binding Corporate Rules stipulate that the data will be processed in accordance with GDPR.
Strettons is certified for Cyber Essentials.
HOW DO WE UPHOLD YOUR RIGHTS TO USE PERSONAL DATA?
We aim to tailor our communications and ensure you are able to ‘opt-in’ to receive the information that you want. To achieve this, we will usually inform you, before collecting your data, if we intend to use your data for such purposes. You can exercise your right to prevent such processing by letting us know in writing. You will always have the right to ask us not to process your personal data for marketing purposes and you can exercise your right to erasure by contacting our Data Protection Officer, Simon Buchanan email@example.com.
WHERE WE STORE YOUR PERSONAL DATA
Your data we collect may be transferred to and stored at our servers in the UK.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to third parties for reasons including the following:
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation
- In order to enforce or apply any agreements
- To protect the rights, property, or safety of Strettons or others
This includes exchanging information with other companies and organisations for the purposes of safeguarding or other statutory regulations we have to comply with.
SECURITY OF YOUR INFORMATION
To help protect the privacy of data and personally identifiable information you transmit through use of this our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
HOW LONG WE STORE YOUR PERSONAL DATA FOR
We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.
In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
Information Commissioner's Office
Tel: 0303 123 1113 (local rate)